Subject: File No. 4-606
From: Richard P Terhune, Jr.

August 2, 2010

#61607 Compliance costs-both in terms of finances and time-are high, and those costs are eventually felt by clients. Adding another layer of regulation means another layer of compliance, and even more cost to my clients.
o I hold multiple licenses in 5 states and must take multiple hours of continuing education to stay current on the laws and practices of those states.
o I am examined several times a year about my CE habits.
o Our agency standards consultant spends an average of 60 hours per week on compliance. He has massive amounts of paperwork to handle for our office, in addition to another office in Windsor, CT.
o In my view, adding additional layers of compliance will not protect consumers any further than current laws.
o Current compliance requirements already enact a heavy burden on advisors to provide information for compliance that doesn't directly benefit consumers or relate to their concerns.
#61607 The liabilities of a fiduciary duty would mean increased costs and limited ability to serve my clients.

Please consider the current level of regulatory requirements and other restrictions that are already in place on honest, ethical advisors, and avoid passing any further legislation to complicate this process.